Can a SEBI-registered Research Analyst guarantee returns or show past performance?

Published 3 November 2026 · Potoos Research Services

What the rules say about guaranteed returns

SEBI sets out the terms every Research Analyst must give a client in its Master Circular for Research Analysts, number HO/38/12/11(1)2026-MIRSD-POD/I/4360/2026, dated 6 February 2026. Three of those terms answer this question directly.

• "Any assured/guaranteed/fixed returns schemes or any other schemes of similar nature are prohibited by law. No scheme of this nature shall be offered to the client by the RA."
• "The RA cannot guarantee returns, profits, accuracy, or risk-free investments from the use of the RA's research services."
• "The SEBI registration, Enlistment with RAASB, and NISM certification do not guarantee the performance of the RA or assure any returns to the client."

So a registration number is not a promise of profit. It tells you the analyst works under SEBI's rules. It says nothing about whether a call will make money.

What the rules say about ads and messages

The same master circular carries SEBI's advertisement code for Research Analysts. It has applied since 1 May 2023. It covers far more than newspaper ads. It names electronic mail, text messaging, messaging platforms, social media platforms, telephone, television and video recordings. A research report also counts as an ad if it promotes the analyst's own services.

The code bans "any promise or guarantee of assured or risk free return to the investors." It also says an ad "shall not imply any assured returns or minimum returns or target return or percentage accuracy or service provision till achievement of target returns".

In plain words: no "assured", no "minimum return", no "target return", no accuracy percentage, and no "we keep serving you until you hit the target". Each of those is on SEBI's banned list.

Can a Research Analyst show past performance?

Only in a narrow way. The advertisement code bans any "reference to past performance or risk-return metrics in respect of the services of Research Analyst unless such risk-return metrics are verified by Past Risk and Return Verification Agency (PaRRVA) and claims using such metrics are made in the manner specified by SEBI."

PaRRVA is the Past Risk and Return Verification Agency. SEBI's circular dated 29 April 2026 (HO/38/14/(4)2026-MIRSD-POD/I/10557/2026) says Care Ratings Limited has been recognised as PaRRVA, with the National Stock Exchange (NSE) acting as the PaRRVA Data Centre. It says Care Ratings "shall begin providing its services on regular basis from May 04, 2026."

The short-term exception for older figures

SEBI's circular dated 30 October 2025 (HO/38/12/11(1)2025-MIRSD-POD/ I/73/2025) allows a limited exception for performance from before PaRRVA started. These are its conditions:

• The figures must be certified by a member of ICAI or ICMAI (chartered or cost accountants).
• They may be given "only on specific request of such client". So you have to ask first.
• They must be shared one to one, and "shall not be made available to general public through public media/website".
• They must carry SEBI's disclaimer, which begins: "The performance data presented herein are not verified by Past Risk and Return Verification Agency (PaRRVA) or any other agency recognized by SEBI for this purpose."
• Performance after PaRRVA started may only be shown as figures PaRRVA has verified.

The exception has an end date. The 29 April 2026 circular says certified older figures may be shared "only up to May 03, 2028". An analyst who wants to use them also had to enrol with PaRRVA. SEBI first set that deadline at 3 August 2026. Its circular dated 3 August 2026 (HO/38/14/(11)2026-MIRSD-POD1/ I/18038/2026) extended it to 3 September 2026.

The 30 October 2025 circular also says that anyone found making claims of return or performance without SEBI's permission is liable for summary proceedings under Regulation 30A(1)(c) of the SEBI (Intermediaries) Regulations, 2008.

Warning signs to watch for

Each of these breaks one of the rules quoted above. You can spot them on a screen, in a chat or on a call.

• The words "guaranteed", "assured", "fixed return" or "risk-free".
• A monthly or yearly return target, or a "minimum return".
• An accuracy or win-rate percentage for the calls.
• "Service continues until you reach the target."
• Profit screenshots or past returns posted in public, on a website, a channel or a group. The exception for older figures is one to one and only on your request.
• A request for your trading or bank login, or an OTP. SEBI's client terms say "The RA shall never ask for the client's login credentials and OTPs".

SEBI's investor charter for Research Analysts, in the same master circular, gives you the next step: "Inform SEBI about Research Analyst offering assured or guaranteed returns". Our page on where to complain about a Research Analyst shows how.

How to check this yourself

1. Open SEBI's rule book

   Tap this link to SEBI's Master Circular for Research Analysts. It opens a PDF on sebi.gov.in. It is 107 pages long. You only need two parts of it.

2. Find the advertisement code

   Go to section 11, "Advertisement code and usage of brand name/trade name". It starts on page 33 of the PDF. Items x and xii, on pages 35 and 36, are the ban on assured returns and the rule on past performance.

3. Find the client terms

   Go to Annexure B, "Minimum mandatory terms and conditions". The "Most Important Terms and Conditions" list there, on pages 60 and 61, has the lines on guaranteed returns quoted above.

4. Hold the claim you received against those lines

   Read the message, ad or post again. Does it promise a return, a target or an accuracy figure? Does it show past returns in public? If yes, ask the analyst in writing whether PaRRVA verified the figures. A registered analyst should be able to answer that plainly.

5. Check the registration too

   A firm that promises returns may not be registered at all. Check its INH number on SEBI's register before you pay. Our step-by-step guide shows each tap.

Sources

Checked on 3 November 2026. Each one is SEBI's own document.

• SEBI, Master Circular for Research Analysts, HO/38/12/11(1)2026-MIRSD-POD/I/4360/2026, 6 February 2026: https://www.sebi.gov.in/legal/master-circulars/feb-2026/master-circular-for-research-analysts_99571.html (PDF: https://www.sebi.gov.in/sebi_data/attachdocs/feb-2026/1770375507051.pdf). Section 11 (advertisement code), section 23 (interim arrangement), Annexure B (MITC), Annexure D (investor charter).
• SEBI, Ease of doing business: Interim arrangement for certified past performance of Investment Advisers and Research Analysts prior to operationalisation of PaRRVA, HO/38/12/11(1)2025-MIRSD-POD/ I/73/2025, 30 October 2025: https://www.sebi.gov.in/legal/circulars/oct-2025/ease-of-doing-business-interim-arrangement-for-certified-past-performance-of-investment-advisers-and-research-analysts-prior-to-operationalisation-of-past-risk-and-return-verification-agency-parrv-_97556.html (PDF: https://www.sebi.gov.in/sebi_data/attachdocs/oct-2025/1761827106127.pdf).
• SEBI, Operationalisation of Past Risk and Return Verification Agency (PaRRVA), HO/38/14/(4)2026-MIRSD-POD/I/10557/2026, 29 April 2026: https://www.sebi.gov.in/sebi_data/attachdocs/apr-2026/1777473564120.pdf.
• SEBI, Extension of timeline for enrolment with PaRRVA, HO/38/14/(11)2026-MIRSD-POD1/ I/18038/2026, 3 August 2026: https://www.sebi.gov.in/sebi_data/attachdocs/aug-2026/1785760104221.pdf.

Common questions

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